CITIPOWER CitiPower Bushfire Mitigation Plan 2019 2024 - Electricity Safety (Bushfire Mitigation) Regulations 2013 - Powercor

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CITIPOWER CitiPower Bushfire Mitigation Plan 2019 2024 - Electricity Safety (Bushfire Mitigation) Regulations 2013 - Powercor
CITIPOWER

CitiPower Bushfire Mitigation Plan
          2019 - 2024

  Electricity Safety (Bushfire Mitigation) Regulations 2013

                              December 9, 2019
                                 Revision 5
         Administrator: Manager Network Safety & Bushfire Mitigation
                           Document No: 05-M800
CITIPOWER CitiPower Bushfire Mitigation Plan 2019 2024 - Electricity Safety (Bushfire Mitigation) Regulations 2013 - Powercor
CitiPower Bushfire Mitigation Plan 2019 - 2024

                                     Contents
                                           1    PLAN INTRODUCTION .............................................................................................................3
                                                1.1       CONTACTS ......................................................................................................................3
                                                1.2       DOCUMENT APPROVALS....................................................................................................3
                                                1.3       DOCUMENT REVISION HISTORY ..........................................................................................3
                                                1.4       PLAN DEFINITIONS ...........................................................................................................4
                                           2    REGULATION COMPLIANCE INFORMATION ...........................................................................4
                                                2.1       LEGISLATION ...................................................................................................................6
                                           3    INTRODUCTION ......................................................................................................................6
                                                3.1       CITIPOWER .....................................................................................................................6
                                           4    BFM POLICY & OBJECTIVES .....................................................................................................7
                                                4.1       POLICY ...........................................................................................................................7
                                                4.2       OBJECTIVES ....................................................................................................................7
                                           5    SCOPE .....................................................................................................................................7
                                                5.1       ELECTRICAL NETWORK MAP ..............................................................................................8
                                           6    MANAGEMENT STRUCTURE ...................................................................................................8
                                           7    POLICIES AND STRATEGIES .....................................................................................................9
                                                7.1       OVERVIEW OF THE ASSET MANAGEMENT SYSTEM .................................................................9
                                                7.2       MONITORING ASSET CONDITION ......................................................................................10
                                                   7.2.1      ASSET INSPECTION CYCLE ............................................................................................11
                                                   7.2.2      THERMAL AND CORONA IMAGING ................................................................................12
                                                   7.2.3      PRIORITY CLASSIFICATIONS ..........................................................................................12
                                                7.3       REMEDIAL MAINTENANCE ...............................................................................................13
2019 - 2024

                                                   7.3.1      DEFECT MANAGEMENT ..............................................................................................13
                                                   7.3.2      FAULTS/FAULT FOLLOW-UP.........................................................................................13
                                                   7.3.3      AUDITS/OBSERVATIONS..............................................................................................13
                                                   7.3.4      NON CYCLIC MAINTENANCE ........................................................................................13
                                                7.4       ASSET REPLACEMENT/MODIFICATION ...............................................................................13
CitiPower Bushfire Mitigation Plan

                                                7.5       PROPOSED PROACTIVE POLE REPLACEMENT ........................................................................14
                                                7.6       ESV DIRECTIONS ...........................................................................................................14
                                                   7.6.1      CURRENT DIRECTIONS ................................................................................................14
                                                   7.6.2      FITTING OF SPACERS IN AERIAL LINES ............................................................................14
                                                   7.6.3      FITTING OF ARMOUR RODS & VIBRATION DAMPERS ........................................................15
                                                7.7       VEGETATION MANAGEMENT ............................................................................................15
                                                7.8       PRIVATE OVERHEAD ELECTRIC LINES (POEL) ......................................................................15
                                                   7.8.1      POEL INSPECTIONS ...................................................................................................15
                                                   7.8.2      POEL DISCONNECTION ..............................................................................................16

                                     1
CITIPOWER CitiPower Bushfire Mitigation Plan 2019 2024 - Electricity Safety (Bushfire Mitigation) Regulations 2013 - Powercor
7.9       NEW TECHNOLOGIES & INITIATIVES...................................................................................16
     7.10      RESOURCING.................................................................................................................17
     7.11      TRAINING .....................................................................................................................17
        7.11.1       ONGOING COMPETENCY ...........................................................................................18
        7.11.2       ASSET INSPECTION ...................................................................................................18
        7.11.3       VEGETATION MANAGEMENT .....................................................................................18
        7.11.4       LINE WORK.............................................................................................................18
        7.11.5       TECHNICAL STANDARDS ............................................................................................19
     7.12      LIAISON WITH OTHER ORGANISATIONS ..............................................................................19
     7.13      PUBLIC AWARENESS .......................................................................................................19
     7.14      ASSISTANCE PROVIDED TO FIRE AGENCIES ..........................................................................20
        7.14.1       EMERGENCIES .........................................................................................................20
        7.14.2       INFORMATION EXCHANGE .........................................................................................20
     7.15      TOTAL FIRE BAN DAYS ....................................................................................................21
     7.16      DECLARED FIRE DANGER PERIOD ......................................................................................21
     7.17      FIRE MANAGEMENT .......................................................................................................21
8    PROGRAM TIMING ...............................................................................................................21
9    FIRE INVESTIGATION ............................................................................................................21
10   KEY MEASURES .....................................................................................................................22
     10.1      BFM INDEX ..................................................................................................................22
     10.2      FIRE STARTS..................................................................................................................22
     10.3      F-FACTOR SCHEME ........................................................................................................22
     10.4      ASSET FAILURES.............................................................................................................23
     10.5      BFM MILESTONES .........................................................................................................23
11   REPORTING AND MONITORING ...........................................................................................23
     11.1      BFM STATUS ................................................................................................................23
     11.2      BFM INDEX ..................................................................................................................24

                                                                                                                                                    2019 - 2024
     11.3      ASSET INSPECTION .........................................................................................................24
     11.4      MAINTENANCE ..............................................................................................................24
     11.5      VEGETATION CLEARANCE.................................................................................................24
     11.6      ESV ............................................................................................................................24
                                                                                                                                                    CitiPower Bushfire Mitigation Plan

12   AUDITING .............................................................................................................................25
     12.1      ASSET INSPECTION AUDITS ..............................................................................................25
     12.2      MAINTENANCE AUDITS ...................................................................................................26
     12.3      VEGETATION AUDITS ......................................................................................................26
     12.4      LINE CONDITION OBSERVATIONS ......................................................................................26
13   REVIEWING...........................................................................................................................26
14   APPENDICES .........................................................................................................................27

                                                                                                                                            2
CITIPOWER CitiPower Bushfire Mitigation Plan 2019 2024 - Electricity Safety (Bushfire Mitigation) Regulations 2013 - Powercor
1 PLAN INTRODUCTION
                                     1.1     C O N T AC T S

                                     Responsibility               Title              Address                   Contact Details

                                     BMP Responsible              CitiPower Pty      40 Market Street          Phone: 13 22 06
                                     Organisation                 Ltd                Melbourne, 3000
                                                                                     Victoria

                                     BMP Preparation              Senior Advisor     40 Market Street          Phone: 13 22 06
                                                                  Bushfire           Melbourne, 3000
                                                                  Mitigation         Victoria

                                     BMP                          Manager            40 Market Street          Phone: 13 22 06
                                     Implementation               Network Safety     Melbourne, 3000
                                                                  & Bushfire         Victoria
                                                                  Mitigation

                                     BMP Emergency               CitiPower Pty       40 Market Street          Phone: 13 12 80
                                     Contact                     Ltd                 Melbourne, 3000           (24 x 7 emergencies and
                                                                                     Victoria                  faults contact number for
                                                                                                               members of the public)

                                     1.2 D O C U M E N T A P P RO V AL S

                                                              Title                Name                  Signature                  Date

                                     Prepared by:             Senior Advisor
                                                              Bushfire             Robert Stevens                                    9/12/2019
                                                              Mitigation

                                     Approved:                Manager
                                                              Network Safety       Dene Ward                                         9/12/2019
                                                              & Bushfire           (Luke Farrugia for)
                                                              Mitigation
2019 - 2024

                                     Endorsed:                General
                                                              Manager              Steven Neave                                     9/12/2019
                                                              Electricity
                                                              Networks
CitiPower Bushfire Mitigation Plan

                                     1.3 D O C U M E N T R E VI S I O N H I S T O RY

                                     Issue     Revision Summary                      Reviewer                                        Date

                                         5     Plan submitted to ESV                 Manager Network Safety & Bushfire Mitigation    10/12/2019

                                     3
1.4        P L A N D EF I N I TI O N S

Act: Electricity Safety Act 1998.

Fire Danger Period: a period declared under section 4 of the Country Fire Authority Act 1958 to be a fire
danger period.

Total Fire Ban Day: a day that has been declared to be a day of total fire ban under section 40(1) of the
Country Fire Authority Act 1958.

For other definitions refer to the Act, Regulations and Code.

2 REGULATION COMPLIANCE INFORMATION
The purpose of this section is to provide assistance to quickly identify the specific items required in
Regulation 7 of the “Electricity Safety (Bushfire Mitigation) Regulations 2013”.

 Regulation         7 - Prescribed particulars for bushfire mitigation plans—major          Reference in this
                    electricity companies.                                                  Plan

 7(1)(a)            the name, address and telephone number of the major electricity         Contacts
                    company;
 7(1)(b)            the position, address and telephone number of the person who was        Contacts
                    responsible for the preparation of the plan;
 7(1)(c)            the position, address and telephone number of the persons who are       Contacts
                    responsible for carrying out the plan;
 7(1)(d)            the telephone number of the major electricity company’s control
                    room so that persons in the room can be contacted in an emergency       Contacts
                    that requires action by the major electricity company to mitigate the
                    danger of bushfire;

 7(1)da             the telephone number of the major electricity company that
                    members of the public can call in an emergency that requires action     Contacts
                    by the major electricity company to mitigate the danger of bushfire;
 7(1)(e)            the bushfire mitigation policy of the major electricity company to      Section 4.1
                    minimise the risk of fire ignition from its supply network;

                                                                                                                2019 - 2024
 7(1)(f)            the objectives of the plan to achieve the mitigation of fire danger     Section 4.2
                    arising from the major electricity company’s supply network;
 7(1)(g)            a description, map or plan of the land to which the bushfire            Section 5.1
                    mitigation plan applies;
 7(1)(h)            the preventative strategies and programs to be adopted by the major     Section 7
                                                                                                                CitiPower Bushfire Mitigation Plan

                    electricity company to minimise the risk of the major electricity
                    company's supply networks starting fires;
 7(1)(i)            a plan for inspection that ensures that –
                         (i) the parts of the major electricity company's supply network    Section 7.2
                             in hazardous bushfire risk areas are inspected at intervals
                             not exceeding 37 months from the date of the previous
                             inspection.
                         (ii) the parts of the major electricity company's supply network
                              in other areas are inspected at specified intervals not
                              exceeding 61 months from the date of the previous
                              inspection.

                                                                                                            4
Regulation   7 - Prescribed particulars for bushfire mitigation plans—major              Reference in this
                                                      electricity companies.                                                      Plan

                                     7(1)(j)          details of the processes and procedures for ensuring that each              Section 7.11
                                                      person who is assigned to carry out inspections referred to in
                                                      paragraph (i) and of private electric lines has satisfactorily completed
                                                      a training course approved by Energy Safe Victoria and is competent
                                                      to carry out such inspections;
                                     7(1)(k)          details of the processes and procedures for ensuring that persons
                                                      (other than persons referred to in paragraph (j) who carry out or will      Section 7.11 & 12
                                                      carry out functions under the plan are competent to do so;

                                     7(1)(l)          the operation and maintenance plans for the major electricity
                                                      company's supply network—
                                                           (i) in the event of a fire                                             Section 7.17
                                                           (ii) during a total fire ban day                                       Section 7.15
                                                           (iii) during a fire danger period                                      Section 7.16
                                     7(1)(m)          the investigations, analysis and methodology to be adopted by the
                                                      major electricity company for the mitigation of the risk of fire ignition   Section 10.4
                                                      from its supply network;

                                     7(1)(n)          details of the processes and procedures by which the major
                                                      electricity company will;
                                                          (i) monitor the implementation of the bushfire mitigation plan;         Section 11
                                                                and
                                                          (ii) audit the implementation of the plan; and                          Section 12
                                                          (iii) identify any deficiencies in the plan or the plan’s               Section 13
                                                                implementation; and
                                                          (iv) change the plan and the plan’s implementation to rectify           Section 13
                                                                any deficiencies identified under subparagraph (iii)
                                                          (v) monitor the effectiveness of inspections carried out under          Section 12
                                                                the plan; and
                                                          (vi) audit the effectiveness of inspections carried out under the       Section 12
                                                                plan.

                                     7(1)(o)          the policy of the major electricity company in relation to the
                                                      assistance to be provided to fire control authorities in the
2019 - 2024

                                                                                                                                  Section 7.12
                                                      investigation of fires near the major electricity company's supply
                                                      network;

                                     7(1)(p)          details of processes and procedures for enhancing public awareness
                                                      of;
                                                          (i) the responsibilities of the owners of private overhead              Section 7.8
                                                                electric lines that are above the surface of the land in
CitiPower Bushfire Mitigation Plan

                                                                relation to maintenance and mitigation of bushfire danger;
                                                          (ii) the obligation of the major electricity company to inspect         Section 7.8
                                                               private overhead electric lines that are above the surface of
                                                               the land within its distribution area.
                                     7(1)(q)          a description of the measures to be used to assess the performance          Section 10
                                                      of the major electricity company under the plan.

                                     5
2.1 L E GI S L A TI O N
Section 113A (1) of the Electricity Safety Act 1998 requires that a major electricity company must prepare and
submit to Energy Safe Victoria, for acceptance under this Division, a plan for the company's proposals for
mitigation of bushfire in relation to the company's supply network at the end of each period of 5 years
commencing on the later of –
         a)   the date when the accepted bushfire mitigation plan is first accepted under this Division; or
         b) the date of the most recent acceptance of a revision of the accepted bushfire mitigation plan
            submitted under this Division.
In accordance with the Electricity Safety (Bushfire Mitigation) Regulations 2013 this Bushfire Mitigation plan
provides the prescribed particulars as specified in Regulation 7.
A copy of the accepted CitiPower Bushfire Mitigation Plan (BMP) will be published on the website of
CitiPower Ltd.
A copy of the current accepted bushfire mitigation plan will be available for inspection at the company's
principal office in the State of Victoria during ordinary business hours.
This plan is a living document and will evolve as the fire danger period approaches each year. Appendices to
this document will be reviewed and additional information may be added to the appendices as it becomes
available.

3 INTRODUCTION
3.1 C I TI PO W E R
CitiPower owns and manages the electricity distribution network in Melbourne's central business district and
inner suburbs.
Statistics regarding the CitiPower distribution network are presented in the table below.
 Attribute                                              Statistic
 Network area                                           157 square kilometres
 Length of distribution network (all lines)             7,324 kilometres
 Underground lines                                      40.67%
 Number of poles (all poles)                            58,660
 Number of zone substation transformers                 106
 Number of distribution substation transformers         4,621
 Total number of customers                              321,567
 Customer density                                       2,048 per square kilometre

                                                                                                                 2019 - 2024
 Network availability                                   99.98%

Figure 1 – CitiPower Network footprint
                                                                                                                 CitiPower Bushfire Mitigation Plan

                                                                                                         6
4 BFM POLICY & OBJECTIVES

                                     4.1 P O L I C Y
                                     To minimise the risk of fire starts from its electrical assets as far as reasonably practicable by complying with
                                     legislative and regulatory requirements, whilst allowing flexibility within the business to encourage
                                     innovation, continuous improvement and the efficient use of resources.

                                     4.2 O B J E C T I V E S
                                     The objectives of this plan are to:
                                                    minimise the risk of fire starts from electrical assets
                                                    achieve compliance with the relevant legislative and regulatory requirements while providing
                                                     flexibility within the business to encourage innovation, continuous improvement and the
                                                     effective use of resources
                                                    define the companies approach to the management of the risk of bushfires caused by
                                                     electricity assets
                                                    Reference the policies and procedures relating to bushfire mitigation activities into one
                                                     reference document
                                                    demonstrate a high level of commitment to meeting bushfire mitigation responsibilities

                                     5 SCOPE
                                     CitiPower’s bushfire mitigation program includes asset inspection, maintenance, construction, upgrading,
                                     replacement, vegetation management, performance monitoring and auditing. The planning and scheduling
                                     of this program is based principally on the system of asset inspection and maintenance reporting supported
                                     by a program of audits.
                                     There are no “hazardous bushfire risk areas” designated within CitiPower’s service area. However the
                                     CitiPower Vegetation Management Plan identifies “Native Vegetation Areas”.
                                     This plan applies to all CitiPower assets that could cause fire ignition. Electricity networks have been a source
                                     of fire ignition since their construction and consequently a considerable amount of investigation has been
                                     and continues to be undertaken into the causes to enable preventative actions to be taken.
                                     The main causes of fire ignition in an electricity distribution network are:
2019 - 2024

                                                    Surface contamination of insulators, combined with moisture, resulting in electrical tracking
                                                     (leading to pole/cross arm fires)
                                                    Failure or malfunction of network devices such as Surge Arresters and HV fuses
                                                    Contact between vegetation and the electricity network
                                                    Bird, or animal, contact with electricity assets
CitiPower Bushfire Mitigation Plan

                                                    Failure of line hardware (electrical and mechanical)

                                     This plan makes reference to other plans, manuals, standards, policies, procedures and work instructions
                                     which, when combined with this plan, cover all of the activities that contribute to the reduction of bushfire
                                     risk.
                                     Other key documents include:
                                                    The Electric Line Clearance Vegetation Management Plan (ELCMP)
                                                    The Asset Management Framework & associated plans
                                                    The Event Command Organisation (ECO) Manual

                                     7
     The Asset Inspection Manual
               Electricity Safety Management Scheme
               Technical Standards (covering design & construction of assets)
               Maintenance Policies
               Technical Bulletins
               The various Manuals, Procedures, Guidelines and Work Instructions covering BFM related
                activities

5.1 E L EC T RI C AL N E TW O R K M A P
Figure 2 – CitiPower Network diagram

Full network details are available from CitiPower’s Graphical Information System (GIS).                             2019 - 2024

6 MANAGEMENT STRUCTURE
CitiPower has a formal management structure for the implementation and control of BFM related activities.
                                                                                                                    CitiPower Bushfire Mitigation Plan

This structure has clearly assigned authorities and responsibilities associated with each position. It takes into
account the inter-relationships between those that manage, perform, record, verify and report bushfire
mitigation activities and has been set up to maintain independence of reporting and monitoring tasks.
External to the BFM management structure are the Audit Services group which annually audit and report on
BFM performance and compliance.
A copy of the current CitiPower Management Structure is available on the Company’s Intranet site.

                                                                                                            8
7 POLICIES AND STRATEGIES
                                     CitiPower uses a number of strategies, plans, policies and standards to achieve its’ Asset Management
                                     objectives. The principle documents for ongoing asset management will be the Network Asset Management
                                     Plans and Specific focus plans/strategies and policies, standards, specifications and guidelines.

                                     7.1 O V E R VI EW O F T H E A S S E T M AN A GE M EN T S Y S T EM
                                     The CitiPower asset management system reflects the structure aligned with ISO 55001. It is structured into
                                     five levels in simplified form as shown in figure 3:
                                               • Level 1: Stakeholder needs and governance;
                                               • Level 2: Asset management objectives aligned with the CitiPower five strategic pillars;
                                               • Level 3: Asset management planning;
                                               • Level 4: Asset management delivery; and
                                               • Level 5: Performance monitoring and review.

                                     Levels 1 and 2 describe ‘What’ asset management strategies and objectives are to be targeted and provide
                                     details regarding ‘Why’ these are required. Level 3 describes the approach taken to plan and budget for the
                                     delivery of the asset management activities, while level 4 describes ‘how’ and ‘when’ these activities are
                                     delivered to meet the strategies and objectives. Level 5 describes CitiPower’s approach to performance
                                     monitoring and review of the asset management system.
                                     Figure 3 - CitiPower asset management system

                                                                      Stakeholder needs                                           Organisational context &
                                                                      & governance                                            organisational strategic direction
                                                       What and why

                                                                                                                            Asset management objectives aligned
                                                                                          Asset information

                                                                                                                                    with corporate plan
                                                                      Strategic
                                                                                              enablers

                                                                      asset
                                                                      management                                            Strategies to meet asset management
                                                                                                                                          objectives
2019 - 2024

                                                                      Asset
                                                                                                                             Planning to meet asset management
                                                                      management                                                          objectives
                                                                                              Asset information enablers

                                                                      planning
                                                       How and when

                                                                      Asset
                                                                                                                           Delivering asset management objectives
                                                                      management
CitiPower Bushfire Mitigation Plan

                                                                      delivery

                                                                      Performance
                                                                                                                                 Performance evaluation &
                                                                      monitoring &                                                   improvement plan
                                                                      review

                                     The relationship between the various strategy and planning documents in CitiPower’s asset management
                                     system is shown in figure 4.

                                     9
Figure 4 – Asset planning, strategies and policy document relationships

CitiPower has developed and implemented a number of policies and procedures across a broad range of
areas to minimise the risk of fire ignition starting from its supply network. These areas include:
           Bushfire Mitigation
           Asset Management
           Incident Reporting & Investigation
           Private Overhead Electric Lines
           Environmental
           Information Technology
           Purchasing and Procurement
           Contract and Contractor Management

The specific policies, strategies and procedures related to BFM activities are described below.

7.2 M O N I TO RI N G A S S E T C O N DI TI O N
Preventative maintenance strategies have been created for all of CitiPower zone substations, sub-

                                                                                                              2019 - 2024
transmission and distribution assets. These strategies were developed from Reliability Centred Maintenance
(RCM II) methodologies and involve undertaking on-condition tasks based on a program of condition
monitoring of the electrical network assets. The RCM rules are configured in the CitiPower Asset
Management Enterprise System, called SAP, which automatically generates time based work orders for
inspection and maintenance planning.
Asset maintenance policies are developed, reviewed and implemented in accordance with:
          Procedure 18-05-P0003 - Asset Maintenance Policy and Asset Management Plan Review and
                                                                                                              CitiPower Bushfire Mitigation Plan

          Development
          Document JEQA4UJ443MT-173-116 - Electricity Safety Management Scheme

These documents outline how CitiPower identifies needs, develops and manages policies and provides a
systematic process through the identification of strategic, operational and program/project level risks to;
          • Determine accountability for risks;
          • Provide an assessment of controls and the control environment;
          • Analyse and evaluate risks; and
          • Manage the risks to as low as reasonably practicable levels.

                                                                                                    10
7. 2.1   Asset Inspection Cycle
                                     Inspection of poles is carried out in a dedicated program conducted over the following cycles
                                     (referred to as cyclic inspections):

                                      Included poles                      Type of inspection                          Cycle
                                      Serviceable poles in HBRA           Above ground inspection                     2.5 years +/- one month

                                      All serviceable poles               Full Inspection                             5 years +/- one month

                                      AC serviceable poles               Above ground inspection                     1 year   +/- six months

                                      AC serviceable poles               Full Inspection                             2 years +/- six months

                                      Added Controls Serviceable Poles (AC Serviceable Poles) are referred to as Limited Life poles in SAP records.

                                     Definition of inspection types:
                                     Full Inspection - Full inspection of pole and pole top assets in accordance with:
                                                Policy 05-C001-D390 – Network Asset Maintenance Policy for Inspection of poles

                                     Pole Above Ground Inspection – Visual inspection of pole and pole top assets in accordance with:
                                                Policy 05-C001-D390 – Network Asset Maintenance Policy for Inspection of poles

                                     Note: This inspection excludes excavation, treatment, and pole assessment at or below ground line.
                                     (Both inspection types include the inspection of electrical assets between poles).

                                     Operational instructions for the inspection, testing and assessment of assets are contained in:
                                                Manual 05-M450 - Asset Inspection Manual
                                     This manual describes the various types of electrical assets and the observations or tests necessary to identify
                                     and assess their condition. It also gives a detailed description of items that need to be identified for
                                     approved replacement or modification programs. The manual sets out criteria for categorising the urgency
                                     for remedial maintenance actions and the reporting and information recording requirements.
                                     Due to access difficulties associated with the inspection of poles located in inaccessible locations these
                                     inspections are conducted in accordance with:
                                                Procedure 18–20–P0004 – Inaccessible Asset
2019 - 2024

                                     The Asset Inspection Officer controls the program of power line inspection in accordance with CitiPower
                                     policies using maintenance plans established within SAP. Each maintenance plan covers all of the poles within
                                     a specific electrically isolatable section of the network. Maintenance plans are managed in accordance with:
                                                Procedure 18–20–P0002 –Asset Inspection
CitiPower Bushfire Mitigation Plan

                                     When SAP transaction “Date Monitoring” is run, pole inspection orders (PINS) are created in accordance with
                                     the scheduled dates specified in the maintenance plans. These work orders are electronically transferred to
                                     the Field Mobile Computing (FMC) system, reviewed by the Asset Inspection Officer and released to the Asset
                                     Inspection contractor. FMC is an interface application, linked to SAP and GIS, that prepares data for dispatch
                                     to the Asset Inspection contractor. Individual work orders are created by the Asset Inspection contractor and
                                     downloaded to individual asset inspectors.
                                     Asset Inspectors carry out the inspections and enter the results into a Portable Data Assistant (PDA). After
                                     inspection the “as found” data, in the PDA, is uploaded to FMC via remote data transfer connection. An
                                     overnight batch run in SAP automatically updates the equipment details as per the uploaded data and raises
                                     Notifications for all defects identified. Each Notification contains details of the defect located on a specific
                                     pole.

                                     11
The Asset Inspection Officer is responsible for preparation of the asset inspection program and monitoring of
the performance of the contractor in adhering to the program. This is performed with the use of exception
reporting to monitor variations from policy. A daily automated report is generated and sent to key
stakeholders across the business.

7. 2.2   Thermal and Corona Imaging
Thermal imaging inspections are undertaken in accordance with:
           Policy No. 05-C001.D-570 - Thermovision policy

Corona imaging inspections are undertaken in accordance with:
           Guideline 18-20-G0001 Corona Camera Application Guideline

The thermal and corona inspection policies/guidelines stipulate the required inspection schedules and repair
timeframes.

7. 2.3   Priority Classifications
Assets defects identified by our inspection program, or are internally/externally reported, are assessed for
their associated risk and prioritised for remedial action.
Any report of a network defect will be managed in accordance with:
           Policy No 05-C001.A-025 - Priority Policy

This policy sets out the criteria for classification of defects as shown in Table 1 below.

Table 1 - Priority Schemes
 Allocation                      Symbol               Allocated to items assessed to be         Need to be
                                                      at risk of failure within the             actioned within
                                                      following timeframes

 Priority 1                      P1                   0-42 days                                 24 hours

 Fault follow up 14 days         FFU14                > 14 days                                 14 days

 Fault follow up 14 days         FFU28                > 28 days                                 28 days

 Priority 42                     P42                 42 days – 32 weeks                         42 days                2019 - 2024
 Priority 2                      P2                  32 weeks – 3 years                         32 weeks

 Priority 3                      P3                   > 3 years                                 3 years
                                                                                                                       CitiPower Bushfire Mitigation Plan

 Priority Opportunistic          POPP                 Not applicable                            No set timeframe –
                                                                                                actioned on an
                                                                                                opportunity basis

 Priority Notification for       PN                   Not applicable                            No set timeframe –
 information                                                                                    information record
                                                                                                only

                                       Extract from Priority Policy (05-C001.A-025) Issue 4.4

                                                                                                                  12
7.3 R E M EDI AL M AI N T EN AN C E
                                     CitiPower’s maintenance programs are generated from a number of different sources, the main one being the
                                     asset inspection program (refer Section 7.1).
                                     Maintenance can also be identified from the following:
                                                    Reports from employees or contractors
                                                    Customer calls
                                                    Line Condition Observations
                                                    BFM Vegetation Audits
                                                    The Report It Application
                                     Refer Section 12 for more information on audits.

                                     7. 3.1    Defect Management
                                     Maintenance works, identified through the inspection program are issued for remediation. Resources are
                                     scheduled to match the needs of the issued projects in order to achieve the required response times.

                                     7. 3.2    Faults/Fault Follow-up
                                     Repairs to defects identified through the Network Faults/Outage process are managed in accordance with:
                                               Procedure 07-30-P00013 - Manage Network Faults
                                               Procedure 07-20-G0013 - Fault Follow-up & Repair

                                     7. 3.3    Audits/Observations
                                     Asset defects identified during audits/observations are communicated in accordance with the particular audit
                                     process.

                                     7. 3.4    Non Cyclic Maintenance
                                     Maintenance found out of cycle is reported using the “Report It” Application.
2019 - 2024

                                     7.4 A S S ET R E PL AC EM EN T /M O DI FI C A TI O N
                                     CitiPower has a number of specific programs that deal with the replacement and modification of CitiPower
                                     assets. These include:
                                                Replacement of HV fuses
                                                Unacceptable types of surge diverters
CitiPower Bushfire Mitigation Plan

                                                Fitting of LV spreaders
                                                Replacement of reinforcement of unserviceable poles
                                                Replacement of deteriorated cross-arms
                                                Replacement of obsolete HV insulators
                                                Bird and Animal Mitigation
                                                Conductor Management

                                     These activities are carried out in accordance with:
                                               Policy No. 05 - C001.D - 320 - High Voltage Fuses

                                     13
Policy No. 05 - C001.D - 540 - Distribution Surge Arresters
          Policy No. 05 - C001.D - 330 - Insulators, Associated Hardware & Bird Covers
          Policy No. 05 - C001.D - 255 - Low Voltage Spreaders
          Policy No. 05 - C001.D - 392 - Management of Unserviceable Poles
          Policy No. 05 - C001.D - 280 - Cross Arms
          Policy No. 05 - C001.D - 398 - Permanent Reinforcing of Wood Poles
          Policy No. 05 - C001.D - 251 - Bare Conductor Policy
          Document No. - 01 - 00 - M0020 – Overhead Conductors Asset Management Plan

In addition to these, CitiPower is progressively replacing the aged and slow operating electromechanical
feeder protection relays at Zone Substations. The new relays have faster operating times which has the
benefit of reducing fault clearance time and reducing fault energy supplied.

7.5 P R O PO S ED P RO AC TI VE P O L E R E PL AC EM EN T
CitiPower is submitting a proposal as part of its 2021 to 2025 Electricity Distribution Price Reset to sustainably
manage its wooden pole population resulting in an increase in wooden pole interventions. This will also
address the heightened safety concerns from the community in relation to the ageing pole population.
The business as usual condition based wood pole replacement volume over the period will be supplemented
with a risk based asset management program of approximately 900 additional pole interventions.
Energy Safe Victoria (ESV) have assessed and provided recommendations to support CitiPower’s wood pole
management strategies.

7.6 ESV D I R EC TI O N S
Under section 141 (2)(d) of the Electricity Safety Act 1998, ESV may issue directions in relation to electrical
safety.

7. 6.1    Current Directions
Bushfire Mitigation related Directions issued by ESV to CitiPower that are currently open include;
           Fitting of Spacers in Aerial Lines : issued 4 January 2011

7. 6.2   Fitting of Spacers in Aerial Lines                                                                          2019 - 2024
This direction was issued on 4 January 2011, with the requirement to establish and deliver a program that
would ensure that
           Bare wire LV spans in HBRA areas are to have LV spreaders fitted – this direction was completed
            in 2011
                                                                                                                     CitiPower Bushfire Mitigation Plan

           Conductors on the same support to maintain minimum separation in accordance with ENA
            document C(b)1 Guidelines for design and maintenance of overhead distribution and
            transmission lines.
                      In HBRA – before 1 November 2015 – this direction was completed 2015
                      All other areas – before 1 November 2020

                                                                                                            14
7. 6.3   Fitting of Armour Rods & Vibrati on Dampers
                                     This direction was issued on 4 January 2011, with the requirement to establish and deliver a program that
                                     would ensure that all locations requiring the fitting of armour rods and/or vibration dampers to be
                                     completed;
                                                In HBRA – before 1 November 2015 - this direction was completed in 2015
                                                All other areas – before 1 November 2020 - this direction was completed in 2018

                                     7.7 V EG E T A TI O N M AN A GE M E N T
                                     CitiPower is responsible for the management of vegetation around power lines and other electricity assets in
                                     its network area. The whole of the CitiPower service area is a “Declared Area”, where the Councils are
                                     managers of public land and are responsible for keeping trees clear of electric lines.
                                     CitiPower’s Vegetation activities are managed in accordance with:
                                                Document – 2019 -2020 Electric Line Clearance (Vegetation) Management Plan V2.6 (ELCMP)
                                     The CitiPower 2019-2020 ELCMP was submitted to ESV for endorsement as prescribed by the Electricity
                                                                                                 nd
                                     Safety (Electric Line Clearance) Regulations 2015. On the 22 July 2019 ESV approved the plan.

                                     7.8 P RI V A T E O V E RH EA D E L EC T RI C L I N E S (POEL)

                                     7. 8.1    POEL Inspections
                                     CitiPower has an obligation under the Electricity Safety Act 1998 to inspect Private Overhead Electric Lines.
                                     POEL lines are inspected to identify any defects, or infringing vegetation, which may affect the fire and/or
                                     electrical safety of the line.
                                     Inspections are undertaken to include the prescribed standards of inspection contained in section 10 of the
                                     Electricity Safety (Bushfire Mitigation) Regulations 2013. There are 3 variations to these prescribed standards
                                     of inspection being applied by CitiPower.
                                     CitiPower meets the required outcomes of regulation 10(1)g(ii), 10(1)g(iii) and 10(1)h(ii) by the inspection
                                     techniques shown in (1) and (2) below.

                                               (1) The condition of hardwood POEL poles located in concrete is determined by drilling down at an
                                               angle to inspect the condition of the pole below concrete level to determine the millimetres of
2019 - 2024

                                               wood free of decay and the presence of termites.

                                               (2) The condition of treated pine POEL poles is determined by assessing the degree of external rot
                                               and also measurement of the pole girth.
                                               CitiPower meets the required outcomes of regulation 10(1)i by the inspection technique described
                                               in (3) below.
CitiPower Bushfire Mitigation Plan

                                               (3) The condition of steel POEL poles located in concrete is determined by a visual inspection down
                                               to the point where the pole enters into the concrete to ensure that the pole retains 75% of steel
                                               thickness in the corroded area when compared against a non-corroded area on the pole.

                                     The POEL inspection program is conducted in accordance with:
                                               Policy No. 05-C001.D-430 - Low Voltage Private Overhead Electric Lines
                                               Policy No. 05-C001.D-431 - High Voltage Private Overhead Electric Lines
                                               Manual No. 05-M450 - CitiPower Asset Inspection Manual

                                     15
CitiPower’s inspection cycle for Private Overhead Electric Lines is as follows:
All Private Overhead Electric Lines required to be inspected, shall be inspected within a 36 month
timeframe.
CitiPower’s asset inspectors attempt to liaise with POEL owners regarding POEL inspection requirements
before commencing any work. If the POEL owner is not home or is not spoken to, the asset inspector will be
required to leave a pamphlet informing POEL owners that an inspection of their POEL was undertaken, a brief
summary of inspection findings and general information regarding POELs including the requirement for
CitiPower to inspect POELs as required under the Electricity Safety Act 1998. A copy of this pamphlet is
contained in appendix C.
The annual POEL mail out ensures that all CitiPower customers who have a POEL will receive a letter and a
brochure. The letter provides relevant information as well as our policy on defective POEL’s. The brochure
covers topics including ownership, maintenance, vegetation clearance, electrical safety, disconnection and a
guide to POEL inspection. The mail out of these normally commences in early November.
CitiPower notifies the owners of up-coming POEL inspections, as required in the Electricity Safety (Bushfire
Mitigation) Regulations 2013. These letters notify the owner which part of the line we will be inspecting and
what will happen if defects are found refer appendix B. Notice is given not less than 21 days and not more
than 45 days before inspection.

7. 8.2    POEL Disconnection
Land owners, or occupiers, who are responsible for a defective POEL, are given up to 30 days to rectify
vegetation infringements or other urgent defects. Every attempt is made to contact the customer by phone
as soon as we become aware of the defect during the declared fire danger period. If such defects are not
corrected within this time the owner, or occupier, is given further written notice following which they are
advised that the matter has been referred to the ESV as required, according to referral advice provided by
ESV.
CitiPower regularly contacts the responsible land owner, or occupier, by telephone to monitor the progress of
corrective action. POEL’s referred to ESV for non-compliance are reinspected in accordance with POEL policy.
Any hazardous POEL’s found during inspections are disconnected to ensure fire and/or electrical safety.
Supply is not restored until the installation is safe to reconnect.
When a disconnection is necessary, CitiPower’s Customer Compliance Group advises the customer and
creates an entry into their Outage Management System (OMS) which in turn prompts the Operations Control
Centre to dispatch a crew to disconnect supply.
Identification and rectification of defective Low Voltage POELs are managed in accordance with the following:
          Procedure JEQA4UJ443MT-158-503 - Identification and Rectification of Defective POELs (LV)

                                                                                                                2019 - 2024
7.9 N EW T EC H N O L O GI ES & I N I TI A TI VE S
CitiPower has implemented numerous new technologies and initiatives to minimise the risk of electricity
assets causing fire ignition.
The Electricity Networks business unit has the charter to optimise the maintenance strategies/policies and
                                                                                                                CitiPower Bushfire Mitigation Plan

continually assess new technologies for the network assets.

Technologies that are currently being assessed include:
               Enclosed Substation Protection
               Use of LiDAR to determine conductor clearances
               Non-destructive technologies for wood pole inspections
               Hi resolution aerial imagery for pole top inspections
               Early fault detection technology

                                                                                                          16
7.10 R ES O U RC I N G
                                     CitiPower ensures appropriate resources are available to carry out the activities outlined in this plan.
                                     Each year, typically in the fourth quarter, historical data is entered into various forecasting models for asset
                                     maintenance activity. The forecasts obtained from these models, for the following years work, are then
                                     entered into CitiPower’s Asset Management System (SAP). Resource requirements are then checked against
                                     the projects listed in SAP and resources are sourced accordingly.
                                     A detailed asset inspection program, of the following years work, is developed and provided to our asset
                                     inspection contractor to enable them to plan their resource requirements to meet the program’s needs.
                                     CitiPower’s vegetation management contractor is required to manage the resourcing of vegetation
                                     management activities throughout the year.

                                     7.11 T R AI N I N G
                                     CitiPower has an established and documented system to ensure that employee and contractors who are
                                     working on or near the Network are suitably competent and adequately trained to carry out their duties.
                                     The key steps that CitiPower has in place to manage competency and training requirements are illustrated in
                                     figure 5:
                                     Figure 5 - Competency and training process
2019 - 2024

                                     In CitiPower, the Electricity Networks business unit sets the training standard for workers who are working on
                                     or near the Network. The training standards are established through the industry committee VESI Skills and
CitiPower Bushfire Mitigation Plan

                                     Training Reference Committee for consistency within the State and nationally through the Australian Industry
                                     & Skills Committee (refer https://www.aisc.net.au/ for more information).
                                     If training is required specifically for CitiPower this is co-ordinated as Enterprise training for employees. For
                                     contractors, requirements for additional training would be included in a contract agreement.
                                     CitiPower has a documented Technical Training Policy and a Technical Training Guideline which references to
                                     training requirements.
                                                Policy JEQA4UJ443MT-173-25 - Training Policy
                                                Guideline Policy JEQA4UJ443MT-173-25 - Training Guideline

                                     17
All Asset Inspectors are required to meet the training requirements as specified in the VESI Skills and Training
Matrix for Asset Inspectors. These training requirements are confirmed by CitiPower when an application
request is made for an Asset Inspector to work on the network.
Where the qualification (being Cert II in ESI Asset Inspection UET20612 or subsequent version) has been
attained in a State or Territory of Australia other than Victoria, induction to CitiPower requirements (including
our procedures) is conducted by a person holding a Certificate IV in Training and Assessment.
CitiPower has developed enterprise specific competency standards for the activity of asset inspection. These
standards provide contractors and training providers with the information necessary to develop appropriate
training courses that will enable individuals to become approved to inspect CitiPower assets.

7. 11.1   Ongoing competency
Audit processes are in place to ensure that there is consistent application of knowledge and skill to the
standard of performance required for asset inspectors.
Asset Inspector audit findings are rated and the cause of the finding identified. This may result in the need
for refresher training or mentoring of the Asset Inspector to ensure the required competency is achieved.
Overall performance of the asset inspector is monitored whereby frequency rates of audits are determined
based on their performance.
CitiPower has implemented the Australian ESI Skills Passport. The Australian ESI Skills Passport system has
enhanced the portability of the ESI workforce by mutual recognition of agreed training standards. Training is
recorded in the passport and can be viewed to confirm currency of training for the task being undertaken.
Further information can be located at www.esipassport.com.au
The training programs for specific job roles in bushfire mitigation activities are described below:

7. 11.2   Asset Inspection
Asset Inspectors working on the CitiPower network are required to hold a Certificate II in Asset Inspection.
                Course Code UET20612 (or subsequent version)
The VESI Skills and Training Matrix stipulate the requirements and frequency of refresher training for asset
inspectors. The matrix is available at www.vesi.com.au

7. 11.3   Vegetation Management
All training requirements for vegetation activities are managed in accordance with the CitiPower’s Electric

                                                                                                                    2019 - 2024
Line Clearance Vegetation Management Plan.
              Document – 2019 -2020 Electric Line Clearance (Vegetation) Management Plan V2.6 (ELCMP)

7. 11.4   Line work
The VESI Skills and Training Matrix stipulate the qualifications and refresher training for a line worker. The
employing company is required to organise training to the standards referred to in the matrix. The employing
                                                                                                                    CitiPower Bushfire Mitigation Plan

company will keep records of all training undertaken.
Line worker apprentices are engaged in bushfire mitigation activities from time to time. This provides
experience in a broad range of tasks. When companies engage apprentices they work under the VESI
Apprentice Supervision Guidelines as published on the VESI website. www.vesi.com.au
Formal training of apprentices is conducted by a Registered Training Organisation. Training is further
supported “on the job” by designated mentors and tradespersons.

                                                                                                            18
7. 11.5   Technical Standards
                                     CitiPower’s Technical Standards group provide information to CitiPower employees, Local Service Agents
                                     (LSAs) and contractors with regard to new initiatives in the design and construction of network assets.
                                     All contractors or other external persons associated with works on CitiPower assets can register with
                                     CitiPower to gain “read only” access to CitiPower’s technical standards.

                                     7.12 L I AI S O N W I TH O TH E R O R G AN I S AT I O N S
                                     CitiPower has procedures/plans for coordinating BFM activities and emergency procedures with relevant
                                     organisations which may include any of the following:
                                                   Energy Safe Victoria (ESV)
                                                   Metropolitan Fire Brigade (MFB)
                                                   State Emergency Service (SES)
                                                   Emergency Management Victoria (EMV)
                                                   Department of Environment Water & Planning (DELWP)
                                                   Victoria Police (VICPOL)
                                                   Bureau of Meteorology (BOM)
                                                   Municipalities
                                                   Other Distribution/Transmission Network Operators

                                     Actions to be undertaken in the event of a major event or emergency are contained in:
                                               Procedure JEQA4UJ443MT-185-28490 Incident Management Procedure
                                               Manual 13–40-CP0001 - Crisis and Emergency System Management Manual
                                               Manual 13-40-M0002 - Event Command Organisation Manual

                                     These documents include the responsibilities for communications with emergency services and other
                                     relevant organisations during events such as:
                                                   Major supply outages
                                                   Major plant faults
2019 - 2024

                                                   Lack of supply capacity (load shedding)
                                                   Fires and Incidents
                                                   Loss of the Operations Control Centre

                                     Communication processes are managed in accordance with:
CitiPower Bushfire Mitigation Plan

                                               Procedure 16–30–P0003 - Coordinating Bushfire Mitigation with other Organisations

                                     7.13 P U B L I C A W AR E N E S S
                                     CitiPower has a commitment to enhancing public awareness of:
                                                   the potential risks associated with POELs
                                                   the risks of planting inappropriate vegetation near electrical lines
                                                   vegetation species suitable for planting near powerlines

                                     19
As a part of Vegetation Management and POEL inspection programs CitiPower provides the following
information brochures to customers:
               “Planting Trees Near Power Lines”
               “POELs - Understanding Your Responsibilities”
               “Powerlines and Your Property”

7.14 A S S I S TA N C E P RO VI D ED T O F I R E A G EN C I E S
The Metropolitan Fire Brigade (MFB) is the fire-fighting agency which operates within CitiPower’s service
area.
CitiPower provides assistance and works with the relevant fire control agency in the investigation of fires near
our electrical assets.
CitiPower’s Emergency Management Liaison Officers (EMLOs) are available to attend fire agency command
centres and provide information or assistance with issues relating to our distribution assets. An EMLO is a
person that acts as a go-between or the link between two organisations to communicate and coordinate their
activities.

7. 14.1   Emergencies
Any requests for resources to assist fire agencies are coordinated by the Network Controller, from CitiPower’s
Operations Control Centre.
Fire emergencies are communicated directly to the Operations Control Centre via a direct phone number for
emergency services organisations. Fault Crews are then promptly dispatched according to the information
received.
CitiPower will work with the relevant fire control agency to provide safe access to a fire or accident scene
involving CitiPower assets. This may include de-energisation of electrical assets upon request.

Actions to be undertaken in the event of a major event or emergency are contained in:
          Procedure JEQA4UJ443MT-185-28490 Incident Management Procedure
          Manual 13-40-CP0001 - Crisis and Emergency System Management Manual
          Manual 13-40-M0002 - Event Command Organisation Manual

CitiPower also has representation on the State Control Centre Electricity Industry roster for Emergency

                                                                                                                   2019 - 2024
Management Liaison Officers (EMLOs). An EMLO will provide the technical or subject matter expertise
relating to the Electricity Industry and embeds an EMLO into the SCC to provide face-to-face coordination.

7. 14.2   Information Exchange
Any opportunity/requests for information exchange between fire agencies and CitiPower will be followed up.
                                                                                                                   CitiPower Bushfire Mitigation Plan

Each year prior to the fire danger period, the CFA and ESV conduct an information briefing and forecast for
the coming season. Information presented includes the likely severity of the season and identification of high
risk areas. This information day is attended by Victorian electricity distributors (including CitiPower),
transmission operators and representatives from the ESV.
The MFB are covered by CitiPower’s Business Relationship Management program, which is a managed
program of meetings with key (major) customers, organisations and stakeholders, to discuss programs, issues
and any suggested improvements.

                                                                                                          20
7.15 T O T AL F I RE B A N D AY S
                                     The communication of TFB days is carried out by the Control and Operations Group after notification from
                                     the CFA.
                                     Since there is no hazardous bushfire risk areas within the CitiPower service area, there are no auto reclose
                                     suppressions or fault energy reduction undertaken, defective POEL’s are not disconnected and observers are
                                     not posted or patrols undertaken of items outside policy on a day of TFB.
                                     For works involving welding, cutting, grinding, or use of naked flame, permits from the appropriate
                                     organisation (e.g. MFB) are used and adhered to.

                                     7.16 D EC L A R E D F I R E D AN GE R P E RI O D
                                     During the Declared Fire Danger Period CitiPower will continue with normal operation of its electrical assets.
                                     The majority of CitiPower’s Operational and Maintenance activities are configured to be undertaken for the
                                     full 12 months of the year, irrespective of Declared Fire Danger Periods.

                                     7.17 F I RE M AN AG E M E N T
                                     In the event of a fire, CitiPower’s Operational and Maintenance activities include:
                                                    Receiving notification from or supplying notification to the relevant fire control agency
                                                     regarding a fire event.

                                                    Liaison with the relevant fire control agency regarding appropriate actions.
                                                    Dispatching field crews for fault rectification or as directed/requested by the relevant fire
                                                     control agency.

                                                    Deployment of Emergency Management Liaison Officers if required to any Incident Control
                                                     Centre established by the relevant fire control authority.

                                                    Fire events are managed in accordance with the following:
                                                     Manual 13-40-M0002 - Event Command Organisation Manual

                                                     Procedure JEQA4UJ443MT-185-28490 Incident Management Procedure

                                     8 PROGRAM TIMING
2019 - 2024

                                     CitiPower have produced a set of combined BFM program milestones which specify the completion dates
                                     required for key BFM activities. A copy of the BFM program milestones document is attached in appendix A.
                                     The asset inspection program dates are determined by the maintenance plan, in accordance with the relevant
                                     asset policy and are generated from SAP (Refer Section 7.2).
                                     Remedial maintenance and asset replacement/modification is completed accordance with the priority
                                     classification policy (refer Section 7.2.3).
CitiPower Bushfire Mitigation Plan

                                     9 FIRE INVESTIGATION
                                     According to ESV reporting guidelines, any fire starts initiated by CitiPower Assets are reported to ESV.
                                     The Network Control Room identifies any fire starts from outage information or from external advice and
                                     notifies the Network Availability Officer (NAO) who in turn investigates each fire according to the information
                                     provided. As a subsequent the NAO enters fire details and submits the electrical incident into the
                                     ‘NAO Incident Notification’ portal of CitiPower’s incident reporting system namely Cintellate. The
                                     Network Safety section will receive a Cintellate email notification and follow-up accordingly.
                                     At the annual BFM post season review, ground fire start statistics are presented and discussed.

                                     21
The following manual and policy cover the reporting requirements for fire starts:
          Procedure JEQA4UJ443MT-185-28490 Incident Management Procedure
          Procedure JEQA4UJ443MT-173-47 F-Factor Fire Start Incident Reporting
          Procedure JEQA4UJ443MT-173-45 Update ESV & AER Reportable Incidents in Cintellate

The Incident Management Procedure describes the requirements for the reporting and investigation of
incidents involving employees and contractors, plant, property, customers or customer installations and
facilities belonging to others where CitiPower assets or works are involved.
The manual ensures that CitiPower meets its responsibilities to employees, customers, members of the public
and regulatory requirements.
Fires initiated from CitiPower assets are reported in accordance with the manual and to the requirements
stipulated in ESVs “Electrical Infrastructure Safety – Electrical Incident and Safety Performance Reporting
Guidelines” located on the ESV website:
https://www.esv.vic.gov.au/pdfs/electrical-incident-and-safety-performance-reporting-guidelines/

10 KEY MEASURES

10.1 BFM I N D E X
The BFM Index is a level of preparedness measured against key elements of CitiPower’s BFM program. It
measures the performance of a range of inspection and maintenance activities against policy targets. The
index is constructed from figures contained in CitiPower’s consolidated BFM status report.
The BFM status report includes a breakdown of the individual elements that comprise the index, with their
respective weightings (“multipliers”), together with the actual incidence of non-compliant items. Elements
covered include asset, vegetation management, pole replacement and priority maintenance compliance with
policy.
The objective is to reduce the index to zero by the start of the Fire Danger Period and to maintain zero
throughout the period.

10.2 F I RE S TA R T S
Reporting on Ground Fires and Pole Fires is done as they occur and reported to ESV. This is carried out in

                                                                                                                    2019 - 2024
accordance with:
          Procedure JEQA4UJ443MT-173-47 F-Factor Fire Start Incident Reporting
          Procedure JEQA4UJ443MT-185-28490 Incident Management Procedure

10.3 F-F AC TO R S C H EM E
                                                                                                                    CitiPower Bushfire Mitigation Plan

The f-factor scheme is a Victorian Government initiative that provides financial incentives to Victorian
electricity distribution businesses to lower the number of fire starts on their networks. If the number of fire
starts rises, the networks are required to pay a penalty.
This scheme provides distributors with an incentive to enhance safety outcomes. Under the scheme,
networks which reduce the number of fire starts relative to their long-term targets receive an incentive
payment.
Conversely, if a network reports a higher number of fire starts relative to their targets, they face penalties or
reduced revenues.

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